I. All DOCUMENTS CONCERNING the UNIVERSITY OF OREGON's past and current record
retention policies.
2. All DOCUMENTS and COMMUNICATIONS CONCERNING the UNIVERSITY OF OREGON's
purchases, uses, applications, and inventories of PCB-CONTAINING PRODUCTS (potential PCBCONTAINING
PRODUCTS are listed on Attachment "A-I,") from 1935 to present.
3. All DOCUMENTS identifying UNIVERSITY OF OREGON facilities, UNIVERSITY OF
OREGON -operated or UNIVERSITY OF OREGON -sponsored activities where PCBCONTAINING
PRODUCTS have been used, and all testing for the presence ofPCBs.
4. All past and current permits issued to the UNIVERSITY OF OREGON authorizing or regulating the
discharge ofPCBs and CONTAMINANTS into waterbodies.
5. All DOCUMENTS and COMMUNICATIONS CONCERNING UNIVERSITY OF OREGON
programs, REGULATIONS, policies, protocols, testing and/or methodologies to determine whether
PCB-CONTAINING PRODUCTS are being used or have been used by the UNIVERSITY OF
OREGON and in its educational programs and facilities.
6. All DOCUMENTS and COMMUNICATIONS CONCERNING the sampling and testing for PCBs
performed by or at the request of the UNIVERSITY OF OREGON of its properties, buildings or
operations.

7. All DOCUMENTS and COMMUNICATIONS CONCERNING the UNIVERSITY OF OREGON's
knowledge of(]) the release of PCBs into the environment, (2) the persistence ofPCBs in the
environment, and (3) the potential adverse human or animal health effects of PCBs. This request
includes, but is not limited to, documents identifying the date or dates the UNIVERSITY OF
OREGON obtained information regarding any of the topics identified in this paragraph or acquired
articles regarding the presence or consequences of PCBs in the environment including:
a. Harvey, G. W. G. Steinhaver, and J.M. Teal. 1973. Polychlorobiphenyls in North Atlantic
Ocean water. Science 180:643-644.
b. Holden, A. V. 1970. Source of polychlorinated biphenyls contamination in the marine
environment. Nature 226:1 220-1221.
c. Jensen, S., A.G. Johnels, M. Olsson, and G. Otterlind. 1969. DDT and PCB in marine
animals from Swedish waters, Nature. 224:247- 250.
d. Peakall, David. 1971 effect ofpolychlorinated biphenyls (PCBs) on the eggshells ofring
doves. Bulletin of Environmental Contamination and Toxicology.
e. Lincer, Jeffery et. al., 1970, Metabolic effects of polychlorinated biphenyls in the American
kestrel. Nature.
f. Risebrough, R. W. 1968. Polychlorinated Biphenyls in the Global Ecosystem, Nature.
g. Risebrough, R. W. and V. Vreeland. 1972. PCB residues in Atlantic zooplankton. Bull. Env.
Cont. Tox. 8:345-355.
h. Risebrough, Robert et. al. 1972. Accumulation of Polychlorinated Biphenyls in Ecosystems,
Environmental Health Perspectives.
1. Schmidt, T. I., A. W. Risbrough, and F. Gress. 1971. Input of polychlorinated biphenyls
into California coastal waters from urban sewage outfalls. Bull. Env. Cont. Tox. 6:235-243.
J. Widmark, G., 1967, Possible Interference by Chlorinated Biphenyls, Journal of the
Association of Official Analytical Chemists.
8. All DOCUMENTS and COMMUNICATIONS CONCERNING research into fish populations and
fish returns in Oregon water bodies, and the sources of any material changes in either.
9. All DOCUMENTS and COMMUNICATIONS referencing OLD MONSANTO, and/or commercial
production of PCBs.
10. All DOCUMENTS and COMMUNICATIONS CONCERNING PCB-related warnings and product
instructions issued by or to the UNIVERSITY OF OREGON.
11. All DOCUMENTS and COMMUNICATIONS CONCERNING policies or standard operating
procedures issued by the UNIVERSITY OF OREGON related to the use, cleanup, or disposal of
PCBs or PCB-CONTAINING PRODUCT(S).
12. All DOCUMENTS and COMMUNICATIONS of investigations by the UNIVERSITY OF
OREGON of FISH KILLS, wildlife deaths and damages to Oregon NATURAL RESOURCES from
CONTAMINANTS or other causes.

13. All original research conducted by UNIVERSITY OF OREGON researchers regarding the putative
impacts of DDT (including DDT, DOE and DOD), PCBs, organochlorine compounds on fish, birds,
mammals, and human health.
14. All COMMUNICATIONS by UNIVERSITY OF OREGON with the U.S. government, any U.S.
state, or their respective subordinate agencies CONCERNING the presence of PCBs in the
environment.
15. All DOCUMENTS and COMMUNICATIONS CONCERNING the litigation styled State of
Oregon v. Monsanto Company et al., Multnomah County Circuit Court Case No. 18CV00540. This
request includes but is not limited to:
a. Consulting agreements;
b. Expert retention agreement;
c. Communications with the litigants or retained expert witnesses regarding the litigation or
PCBs;
d. Communications between any lawyer from law firms Stoll Berne or Keller Rohrback and
the UNIVERSITY OF OREGON regarding PCBs; and
e. Communications between any lawyer from OREGON DEPARTMENT OF JUSTICE and
the UNIVERSITY OF OREGON regarding PCBs.

ATTACHMENT "A-1"-POTENTIAL PCB-CONTAINING PRODUCTS
No. POTENTIAL PCB-CONTAINING PRODUCTS1
1. Electrical transformers & switches and fluids
2. Canacitors & fluids
3. Compressor lubrication fluids
4. Hvdraulic fluids
5. Heat transfer fluids
6. Caulks
7. Yellow road/traffic paints ( e.g., Ennis standard #2, Sherwin Williams Promar)
8. White road/traffic naints ( e.g., Ennis standard #2, Sherwin Williams Promar)
9. Hvdrant naints (e.g., Rustoleum Pro HP Enamel - Aluminum)
10. Utiiitv locate naints ( e.g., Rustoleum Industrial Choice, Solvent-based)
11. Class B Firefighting Foam (e.g., Alcoseal 3-3 (AR-FFFP))
12. De-icers ( e.g., magnesium chloride, FreezGard/FreezeGard)
13. Vehicle wash soans (e.g., SunerXL, Hotsy, Simple Green)
14. Pesticides/herbicides (e.g., 2-4D, Nufarm Weedar 64, Portfolio 4F, Wilbur-Ellis)
15. Motor oil (new and used) (e.g., Firebird, Valvoline)
16. Diesel
17. Gasoline ( e_g_, regular unleaded)
18. Dirt road sunnressants
19. Lubricants (e.g., MP Gear Lube SAE 85W-140)
20. Asohalt tacks
21. Crack sealers
22. Asnhalt release agents (e.g., Soy What, TechnicChem Corn.)
23. Hvdroseed and hvdromulch (e.g., Natures Own Hvdroseeding Mulch)
24. PVC nine (e.g., ASTM 3034 8", Diamond PVC)
25. CIPP liner
26. Shortliner
27. Thermoplastic tape road strining (e.g., Ennis-Flint Pre-Mark)
28. Antifreeze ( e.g., Kool Green Extended Life)
29. Hand soans ( e.g., Dial Antibacterial)
30. Laundrv soaps ( e.g., Tide original)
31. Dish soaps ( e.g., Dawn Ultra antibacterial)
32. Shamnoos (e.g., Suave naturals)
33. Toothpastes (e.g., Aquafresh Extreme Clean Whitenin°1
34. Fish Feed
35. Paints, inks and dves
36. Recvcled paper products
1This list is for representative purposes only, and is not exhaustive, exclusive, and does not imply
any limitation regarding any other potential PCB-CONTAINING PRODUCTS purchased and/or
used from 1935 to present.